Privacy Policy
This Privacy Policy (“Policy”) describes the practices of the operator of Temina Fit (hereinafter referred to as “Temina Fit,” “we,” “us,” or “our”) regarding the collection, use, storage, disclosure, transfer, retention, and protection of information, including Personal Data and Sensitive Personal Data, obtained from or about individuals who access or use the Services (hereinafter referred to as “User,” “you,” or “your”). This Policy is intended to comply, where applicable, with requirements under the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the UK GDPR, the California Consumer Privacy Act as amended by the CPRA (“CCPA/CPRA”), and other applicable data protection and privacy laws.
Nothing in this Policy constitutes medical advice, a medical device certification, or a guarantee of fitness outcomes. Temina Fit is a software-based fitness and wellness tool. You should consult a qualified healthcare professional before beginning any exercise program.
Article 1. Definitions and Interpretation
For the purposes of this Policy, the following terms shall have the meanings set forth below, unless the context requires otherwise:
- “Personal Data” means any information relating to an identified or identifiable natural person, including but not limited to identifiers such as name, email address, online identifier, or factors specific to physical, physiological, genetic, mental, economic, cultural, or social identity.
- “Sensitive Personal Data” or “Special Category Data” means Personal Data revealing physical or mental health, biometric data for the purpose of uniquely identifying a natural person, data concerning health, fitness, or wellness where such data is treated as sensitive under applicable law, and any other category of data classified as sensitive or special category data under applicable legislation.
- “Processing” means any operation or set of operations performed on Personal Data, whether or not by automated means, including collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination, alignment, combination, restriction, erasure, or destruction.
- “Controller” means the entity that determines the purposes and means of Processing Personal Data. For the Services described herein, Temina Fit acts as the Controller unless otherwise stated.
- “Processor” means a natural or legal person, public authority, agency, or other body that Processes Personal Data on behalf of the Controller.
- “Device Permissions” means permissions requested by the mobile application through the operating system of your device, including but not limited to camera access, location access, and network access.
- “AI Features” means functionality involving automated analysis, recommendation, classification, or generation, including pose estimation, workout plan generation, coaching suggestions, and related machine-learning or large-language-model services.
Headings in this Policy are for convenience only and shall not affect interpretation. References to “including” or “includes” shall be deemed to mean “including, without limitation.”
Article 2. Scope of Application
This Policy applies to Personal Data Processed in connection with:
- the Temina Fit Android mobile application distributed via Google Play and any subsequent versions thereof;
- the website located at temina.fit and associated subdomains, progressive web application components, and service workers;
- account registration, authentication, and session management across the app and website;
- API endpoints, backend services, databases, and cloud infrastructure used to operate the Services;
- customer support communications, privacy-related inquiries, and data subject requests.
This Policy does not apply to third-party websites, applications, or services that may be linked from the Services, nor to data collected offline unless expressly incorporated by reference. We are not responsible for the privacy practices of third parties, and your use of third-party services is governed by their respective policies.
Article 3. Data Controller and Contact Information
The Controller responsible for Processing your Personal Data in connection with the Services is the operator of Temina Fit. For privacy-related inquiries, data subject requests, or complaints regarding this Policy, you may contact us at:
Email: privacy@temina.fit
Subject line (recommended): “Privacy Inquiry — Temina Fit”
We will endeavor to respond to legitimate requests within the timeframes required by applicable law. We may request additional information to verify your identity before fulfilling certain requests.
Article 4. Categories of Personal Data Collected
Depending on your interaction with the Services, the Device Permissions you grant, and the features you enable, we may collect, receive, generate, or otherwise Process the categories of data described below. Not all categories apply to every User at all times.
4.1. Account and Identity Data
When you register for an account, we may collect username, email address, authentication credentials (stored in hashed or otherwise protected form), account identifiers, registration timestamps, login history, session tokens, and related metadata necessary to authenticate you and maintain account integrity.
4.2. Profile, Demographic, and Fitness-Related Data
During onboarding, assessment questionnaires, fitness profile configuration, or settings updates, you may voluntarily provide age, gender or gender-related selections, height, weight, target weight, fitness level, activity level, training frequency, equipment availability, muscle focus preferences, fitness goals, motivation factors, sleep quality indicators, sleep duration bands, health limitations or chronic condition indicators (where applicable and voluntarily disclosed), notes, and other wellness-related information. Such data may constitute Sensitive Personal Data under certain jurisdictions.
4.3. Workout, Activity, and Performance Data
We Process data relating to your use of fitness features, including but not limited to exercise type, repetitions, sets, duration, calories estimated or recorded, step counts, running distance, pace, route coordinates where applicable, workout completion status, streaks, experience points, skill attributes, quest progress, leaderboard rankings, achievements, fatigue indicators, and historical statistics aggregated over time.
4.4. Camera, Image, and Biometric-Adjacent Data
If you enable AI form analysis or related camera-based features, the application may access the device camera and Process video frames or still images for pose detection, movement analysis, repetition counting, or technique feedback. Processing may occur locally on your device, on our servers, or through a combination thereof. We do not activate the camera without your explicit permission through the operating system. We do not use camera data for purposes unrelated to the enabled feature without additional notice and, where required, consent.
4.5. Location and Geolocation Data
If you use run tracking, map visualization, or related location-dependent features, and if you grant location permissions, we may collect precise or approximate geolocation data, including GPS coordinates, timestamps associated with location fixes, route polylines, elevation where available, and derived metrics such as distance and speed. Location data is collected only when the relevant feature is active and permission has been granted, subject to operating system behavior and device settings.
4.6. Technical, Log, and Diagnostic Data
We automatically collect certain technical information when you access the Services, including device model, operating system version, application version, language settings, IP address, network connection type, crash reports, error logs, performance metrics, API request metadata, security event logs, and anti-abuse signals. This information is used to operate, secure, maintain, and improve the Services.
4.7. Communications and Support Data
If you contact us for support or submit a privacy request, we may Process the content of your communications, contact details, attachments you provide, and correspondence history for the purpose of responding to and documenting your inquiry.
Article 5. Sources of Personal Data
Personal Data may be obtained from the following sources:
- directly from you when you register, complete assessments, configure settings, perform workouts, or communicate with us;
- automatically from your device and application when you use the Services;
- from synchronized sessions between the mobile application and website where you use the same account;
- from service providers acting as Processors on our behalf, strictly to the extent necessary to provide contracted services.
Where Personal Data is required to provide core functionality and you choose not to provide it, certain features may be unavailable, degraded, or inoperable.
Article 6. Purposes of Processing and Legal Bases
We Process Personal Data for the purposes described below. Where GDPR or similar laws apply, we rely on one or more of the following legal bases: (a) performance of a contract; (b) consent; (c) legitimate interests; (d) compliance with legal obligations; and/or (e) protection of vital interests, where applicable.
6.1. Provision and Administration of the Services
We Process account and authentication data to create, maintain, and secure your account, enable login and logout, synchronize data across platforms, and provide core application functionality. Legal basis: contract performance; legitimate interests in account security.
6.2. Personalization of Fitness Content
We use profile, assessment, and activity data to generate personalized workout plans, recommendations, difficulty adjustments, gamification elements, and progress visualizations. Legal basis: contract performance; consent where required for sensitive categories.
6.3. AI-Assisted Coaching and Automated Analysis
We may use automated systems, including third-party AI services, to analyze movement, generate coaching feedback, produce training suggestions, and improve model performance. Such Processing may involve profiling in a limited sense (i.e., categorizing fitness level or exercise performance). We do not make decisions producing legal or similarly significant effects solely by automated means without human involvement where prohibited by law. Legal basis: contract performance; consent for camera/health-related inputs where required; legitimate interests in product improvement.
6.4. Security, Fraud Prevention, and Abuse Detection
We Process technical and behavioral data to detect unauthorized access, enforce rate limits, investigate suspicious activity, protect Users and infrastructure, and comply with security obligations. Legal basis: legitimate interests; legal obligation where applicable.
6.5. Service Improvement, Analytics, and Research
We may analyze aggregated or de-identified usage patterns to understand feature adoption, diagnose defects, plan product development, and evaluate service quality. Where feasible, we prefer aggregated or anonymized data for analytics. Legal basis: legitimate interests, balanced against your rights and freedoms.
6.6. Legal Compliance and Enforcement
We may Process and retain data as necessary to comply with applicable laws, respond to lawful requests from public authorities, establish, exercise, or defend legal claims, and enforce our terms. Legal basis: legal obligation; legitimate interests.
Article 7. Device Permissions
The mobile application may request the following permissions through your device operating system. Denying a permission may limit or disable related functionality but will not necessarily prevent use of unrelated features.
- Internet / Network Access: required for account synchronization, API communication, and content delivery.
- Camera: required for AI-based exercise form analysis when such feature is enabled by you.
- Location (Fine and/or Coarse): required for run tracking, route mapping, and location-based metrics when such features are enabled by you.
You may revoke permissions at any time through your device settings. Revocation does not affect the lawfulness of Processing based on consent prior to withdrawal, to the extent permitted by applicable law.
Article 8. Disclosure and Sharing of Personal Data
We do not sell Personal Data as the term “sell” is defined under the CCPA/CPRA. We do not share Personal Data for cross-context behavioral advertising unless explicitly disclosed and permitted. We may disclose Personal Data to the categories of recipients described below, subject to contractual and legal safeguards.
8.1. Infrastructure and Hosting Providers
We use cloud hosting, database, storage, backup, and content delivery providers to operate backend systems on which account, workout, and profile data are stored and Processed.
8.2. AI and Machine Learning Service Providers
When you use AI Features, limited data (which may include text prompts, structured profile fields, or derived movement metadata) may be transmitted to third-party AI providers such as Google (Gemini) or Groq for inference, subject to their terms and our instructions. We configure such services for service delivery purposes and do not authorize providers to use your Personal Data to train public models where opt-out or contractual restrictions are available.
8.3. Mapping and Location Services
Google Maps Platform or similar mapping services may receive location and map-related data when you use map or route visualization features, in accordance with Google’s applicable terms and policies.
8.4. Professional Advisors and Legal Disclosures
We may disclose information to lawyers, auditors, insurers, or consultants under confidentiality obligations, or when required by court order, subpoena, regulatory inquiry, or other lawful process.
8.5. Business Transfers
In the event of a merger, acquisition, reorganization, sale of assets, or insolvency proceeding, Personal Data may be transferred to a successor entity, subject to this Policy or a successor policy providing comparable protections and required notice where applicable.
All Processors are required to Process Personal Data only on documented instructions, implement appropriate security measures, and assist with data subject rights where applicable, pursuant to data processing agreements or equivalent contractual terms.
Article 9. International Data Transfers
Your Personal Data may be transferred to, stored in, and Processed in countries other than your country of residence, including countries that may not provide the same level of data protection as your jurisdiction. Where required by GDPR or other applicable law, we implement appropriate safeguards for international transfers, which may include Standard Contractual Clauses approved by the European Commission, supplementary measures where necessary, and assessments of transfer impact. By using the Services, you acknowledge that such transfers may occur as described in this Policy, to the extent permitted by law.
Article 10. Data Retention
We retain Personal Data only for as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is required or permitted by law. Retention periods may vary based on data category, legal requirements, and operational necessity.
- Account data: retained for the duration of account existence and for a limited period thereafter to handle disputes, backups, or legal obligations.
- Workout and activity history: retained while your account is active and until deletion is requested or the account is closed, subject to backup retention cycles.
- Camera and location data: retained only as long as necessary to provide the relevant feature, generate statistics, or comply with legal obligations; raw frames may be discarded after processing where technically feasible.
- Logs and security records: retained for a limited operational period consistent with security and compliance needs.
Upon verified deletion request or account closure, we will delete or anonymize Personal Data within a commercially reasonable timeframe, except where retention is required for legal compliance, fraud prevention, establishment of legal claims, or backup systems that are purged on scheduled cycles.
Article 11. Security Measures
We implement administrative, technical, and organizational measures designed to protect Personal Data against unauthorized access, alteration, disclosure, or destruction. Such measures may include, without limitation: encrypted transmission via HTTPS/TLS; password hashing; access controls and authentication for administrative systems; network segmentation; logging and monitoring; and periodic review of security practices.
Notwithstanding the foregoing, no method of transmission over the Internet or method of electronic storage is completely secure. We cannot and do not guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying us promptly of any suspected unauthorized access.
Article 12. Your Rights and Choices
Depending on your jurisdiction, you may have one or more of the following rights with respect to your Personal Data, subject to exceptions and limitations under applicable law:
- Right of access: to obtain confirmation as to whether Personal Data is being Processed and to receive a copy of such data.
- Right to rectification: to request correction of inaccurate or incomplete Personal Data.
- Right to erasure (“right to be forgotten”): to request deletion of Personal Data under certain circumstances.
- Right to restriction of Processing: to request limitation of Processing under certain circumstances.
- Right to data portability: to receive Personal Data in a structured, commonly used, machine-readable format where applicable.
- Right to object: to object to Processing based on legitimate interests or for direct marketing, where applicable.
- Right to withdraw consent: where Processing is based on consent, without affecting the lawfulness of prior Processing.
- Right not to be subject to certain automated decisions: where applicable and required by law.
California residents may additionally have rights to know, delete, correct, and opt out of certain sharing, as defined under CCPA/CPRA. To exercise any applicable right, contact privacy@temina.fit. We may deny requests where an exception applies or where we cannot verify identity. You may lodge a complaint with a supervisory authority in your jurisdiction if you believe Processing violates applicable law.
Article 13. Children’s Privacy
The Services are not directed to, marketed to, or intended for use by individuals under the age of thirteen (13), or under the minimum age required for consent in the relevant jurisdiction. We do not knowingly collect Personal Data from children below such age. If you are a parent or guardian and believe that your child has provided Personal Data to us, please contact us immediately at privacy@temina.fit. Upon verification, we will take steps to delete such information as required by applicable law.
Article 14. Cookies, Local Storage, and Similar Technologies
The website and progressive web components may use cookies, local storage, session storage, and similar technologies to maintain login sessions, remember preferences (including language selection), and support core functionality. You may control cookies through your browser settings; disabling certain cookies may impair website functionality. We do not use cookies for third-party advertising profiles unless separately disclosed.
Article 15. Third-Party Links and Integrations
The Services may contain links to third-party websites, applications, or services. This Policy does not govern those third parties. Your interactions with third parties are subject to their privacy policies and terms. We encourage you to review such policies before providing Personal Data to third parties.
Article 16. Health and Medical Disclaimer
Information provided through the Services, including AI-generated recommendations, statistics, calorie estimates, and form feedback, is provided for general fitness and informational purposes only. It is not intended to diagnose, treat, cure, or prevent any disease or medical condition. Temina Fit is not a medical device unless expressly certified otherwise in a specific jurisdiction. Always seek professional medical advice before starting or modifying an exercise program, especially if you have disclosed health limitations or chronic conditions.
Article 17. Changes to This Policy
We reserve the right to modify, amend, or update this Policy at any time to reflect changes in law, technology, business practices, or the Services. Material changes will be posted on this page with an updated effective date. Where required by law, we will provide additional notice or obtain consent. Your continued use of the Services after the effective date of a revised Policy constitutes acknowledgment of the updated terms, to the extent permitted by applicable law. If you do not agree with a revised Policy, you must discontinue use of the Services and may request account deletion.
Article 18. Limitation of Liability
To the maximum extent permitted by applicable law, Temina Fit shall not be liable for any indirect, incidental, special, consequential, or punitive damages arising out of or related to unauthorized access to or alteration of your transmissions or data, except where such limitation is prohibited by law. Nothing in this Policy limits liability that cannot be limited under applicable consumer protection legislation.
Article 19. Severability and Entire Agreement
If any provision of this Policy is held invalid or unenforceable, the remaining provisions shall remain in full force and effect. This Policy, together with any applicable Terms of Service and platform-specific disclosures (including Google Play Data safety declarations), constitutes the entire privacy disclosure regarding the Services, superseding prior informal communications on the same subject matter, except where otherwise required by law.
Article 20. Governing Law and Dispute Resolution
This Policy shall be interpreted in accordance with applicable data protection and consumer protection laws of your jurisdiction where mandatory rules apply. Where no mandatory rule applies, disputes arising from this Policy may be subject to the jurisdiction and venue specified in our Terms of Service or, if none exist, to the courts competent at the Controller’s principal place of business, without prejudice to your statutory rights to bring proceedings in your country of residence where applicable under GDPR or similar laws.
Article 21. Contact
For questions, concerns, complaints, or requests relating to this Privacy Policy or our Processing of Personal Data, please contact:
Temina Fit — Privacy Office
Email: privacy@temina.fit
Website: https://temina.fit
We will acknowledge receipt of verified data subject requests and respond within the timeframe required by applicable law, typically within thirty (30) days for GDPR requests unless extension is permitted and communicated.